SUMMARY OF CHANGES: GECA PERSONAL CARE PRODUCTS STANDARD VERSUS PCPv PERSONAL CARE PRODUCTS STANDARD

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1 SUMMARY OF CHANGES: GECA PERSONAL CARE PRODUCTS STANDARD VERSUS PCPv PERSONAL CARE PRODUCTS STANDARD This document outlines the changes made to the GECA 06 Personal Care Products standard. Criteria updated as a result of independent research, advice from a Technical Advisory Group comprised of manufacturers and other industry experts, and public comments are shown below in their original and revised forms - the change summarised in the last column. GECA PCPv Changes Summary SCOPE OF STANDARD Hair sprays, shaving foams, deodorant sprays, deodorant sticks, deodorant roll-ons and a range of bathroom personal care products related to personal health, hygiene and appearance. FITNESS FOR PURPOSE The products meets or exceeds the requirements of the relevant Australian Standard, or the product meets the applicable and accepted standard in its target market if it is to be exported. Liquid and solid soaps, shaving cream and foams, facial toners, exfoliants, moisturizers, deodorants, cosmetics, nail polish and removers, tanning lotions, perfumes and cologne, sunscreen, insect repellents, personal hand sanitizers, oral hygiene products, hair shampoos and conditioners, hair treatments and styling products. This standard excludes personal care products not applied to persons. Single and multi-use wipes and cloths are not covered by this standard. Aerosols, including products packaging in pressurized cans or cans requiring the use of propellants are not accepted for certification. The product must demonstrate fitness for purpose or market acceptance or suitability or quality. Scope expanded to include multiple types of personal care products, and the types of products one would expect to be certified under a personal care products standard. Exclusion of aerosols based on the availability of products which perform the same function but are more environmentally preferable. Exclusion of single- and multi-use wipes. Criterion update to reflect lack of Australian Standard for personal care products. Multiple DoCs included to provide flexibility for applicant.

2 PALM OIL No Criterion. PALM KERNEL OIL VOLATILE ORGANIC COMPOUNDS (VOCS) At least 20% of palm oil and palm oil derivatives must be sourced from RSPO certified plantations, with the remaining to be covered by GreenPalm certificates, or similar. The applicant must commit to increasing RSPO certified palm oil and palm oil derivatives by 10% p/a. Exemption: If only chemical derivatives of palm oil are used in the product, it is acceptable to demonstrate sustainability for these through book and claim systems such as GreenPalm in case RSPO certified palm oil derivatives are not available on the market. The applicant/licensee must make a positive contribution to the production of sustainable and responsibly grown palm kernel oil (PKO) by either purchasing certified PKO and PKO derivatives, or purchasing all PKO and PKO derivatives from RSPO members, or ensuring all PKO and PKO derivatives used in the product are offset using a Book and Claim system. The total amount of volatile organic compounds (VOCs) contained in the product must meet the limits below (% by weight, as used) Nail polish and nail polish removers:2% Perfume, colognes, toners and personal hand sanitisers: 5% (ethanol exempt for this product category) Other liquid formulations (including mouthwash, deodorants, lotions, moisturisers, soaps, shampoos and conditioners): 10% Other solid formulations (including toothpaste, deodorants, cosmetics and soaps): 1% New criterion added to address concerns regarding the prevalence of unsustainable palm oil sourcing. Whilst RSPO certification is highly regarded, it is unrealistic to expect manufacturers to solely use RSPO palm oil. The GreenPalm book and claim system accommodates for this but still supports sustainable palm oil production. This criterion therefore ensures GECA licensees support the use of sustainable palm oil. New criterion added to address concerns regarding the prevalence of unsustainable palm kernel oil sourcing. As certified PKO derivatives may not be available on the market at present, it is accepted that manufacturers support the sustainable sourcing of PKO through purchasing from RSPO members or by offsetting using a book and claim system which still supports sustainable palm kernel oil production. New criterion added due to growing awareness of health consequences of VOCs. FRAGRANCES Fragrance must be produced and used in accordance with the Code of Practice compiled by the IFRA. New criterion added to address the unique requirements of fragrances separately.

3 COLOURANTS PRESERVATIVES AND BIOCIDES PHOSPHORUS AND PHOSPHATES SODIUM Colorants used must be included on the List of Colouring Agents Allowed for use in Cosmetic Products in Annex IV of the European Union Commission Directive 76/768/EEC. Substances with no recognised function other than biocidal activity may be added for preservation purposes only. Materials added for preservation purposes will be used at the minimal concentration which provides the required function. Preservatives must be listed and abide by the restrictions outlined in the EU Cosmetics Directive 76/768/EEC. Applies to products which are in contact with the body for a short time before rinsing off with water and / or entering wastewater systems only. The product must not be manufactured using phosphorus, phosphorus compounds, phosphates or phosphate derived ingredients. Applies to products which are in contact with the body for a short time before rinsing off with water and / or entering wastewater systems only. Products must not contain more than 5% w/w sodium, excluding water content. New criterion added to address the unique requirements of colorants separately. New criterion added to address the unique requirements and toxicity of preservatives and biocides separately. New criterion to ensure phosphorus and phosphates are not used in personal care products. New criterion added to begin to address use of sodium in personal care products, as part of wider movement to reduce sodium (which can lead to salinity) in all GECA certified products.

4 BIODEGRADABILITY ENVIRONMENTAL CLAIMS Applies to products which are in contact with the body for a short time before rinsing off with water and / or entering wastewater systems only. All surfactants and organic ingredients must be readily biodegradable according to AS 4351, relevant OECD tests, or shown on the most recent DID List (Part A). In the case that numerous ingredients are not reported on the DID list, the product may be tested as a whole to AS 4351 or a relevant OECD test. All surfactants used in the product must be anaerobically biodegradable according to ISO or shown on the most recent DID List (Part A). Food safe claims must be verified by Food Standards Australia and New Zealand. Organic claims must contain 95% ingredients certified as organic by Australian Certified Organic, Organic Growers of Australia, National Association for Sustainable Agriculture Australia (NASAA) Certified Organic or Demeter Certified Biodynamic. Organic Ingredients claims must have certification from one of the above bodies, and organic ingredients shall be identified as so on the label of the product. Natural claims are banned. Contains plant-derived ingredients allowed if claims can be verified, and the plant-derived substance is not mixed or substituted wholly or partly with a synthetic analogue. Not Tested on Animals claims must be able to provide evidence of recognition of this claim by PETA, Choose Cruelty Free or similar. Therapeutic claims must be recognized by the TGA. New criterion added to ensure products that are released into the environment are biodegradable and therefore unlikely to persist. New criterion added to address widespread greenwashing in personal care products industry and to ensure GECA certified products are not misleading.

5 DANGEROUS GOODS The product as used must not be classifiable as hazardous according to NOHSC or SWA / WHS criteria. Ultraconcentrates may be classified as irritants. The product as supplied and as used must not be classifiable as dangerous according to NOHSC criteria or Code of Practice (CoP) for Managing Risks of Hazardous Chemicals in the Workplace or ADG Code, including classification as an Environmentally Hazardous Substance. This includes substances with a potentially corrosive ph (below 2 and above 11.5) and substances carrying R34 or R35. Perfume, colognes, toners and personal hand sanitisers are exempt from this criterion if the product is classified on basis of flammability. New criterion added to ensure GECA products do not carry hazardous or dangerous classifications.

6 BANNED SUBSTANCES The product must not contain any substances carrying any of the following classifications; R20 (H332), R21 (H312), R22 (H302), R23 (H331), R24 (H311), R25 (H301), R26 (H330), R27 (H310), R28 (H300) R33 (H372, H373), R34 (H314), R35 (H314), R36 (H319), R37 (H335), R38 (H315), R39 (H370) R40 (H351), R41 (H318), R42 (H334), R43 (H317), R45 (H350), R46 (H340), R48 (H372,H373), R49 (H350) R60 (H360), R61 (H360), R62 (H361), R63 (H361), R64 (H362), R65 (H304), R66 (AUH066), R67 (H336), R68 (H341,H371) EU C/M/R; IARC Group 1* and 2A Ethanol excluded from above. Preservatives and biocides are exempt from above up to a concentration of 1% by weight. Hydrogen peroxide is exempt from above if the concentration in the final product is equal to or less than 5% by weight. Exemptions may be granted for a specific substance classified with R20, R21, R22, R36, R38, R41, R66, R67 provided that: - the product is not intended for facial, oral or intimate hygiene applications, or for use on infants - there is justification for the substance to be present in the product - the overall product is not classified with any of these R-phrases. Nanoparticles must not be added to product. Chemical UV absorbers must not be added to product. New criteria added to reflect the strengthen requirements of the revised standard. Hazard statements added as an update.

7 Following substances are banned; - Aluminium and aluminium compounds; - APEO and other alkylphenol derivatives (excluding phenoxyethanol); - Aziridine or polyaziridines; - Butoxyethanol; - Formaldehyde or formaldehyde donors; - Quaternary ammonium compounds that are not readily biodegradable, monoethanolamine (MEA) and triethanolamine (TEA); - Halogens and halogenated compounds*, including reactive chlorine compounds (e.g., hypochlorites), organic chlorine carriers (e.g. triclosan), and benzalkonium chloride; - Heavy metals including antimony (Sb), arsenic (As), cadmium (Cd), chromium (Cr), cobalt (Co), lead (Pb) mercury (Hg), and tin (Sn); - Optical brighteners; - Parabens; - Phthalates; - Selenium and selenium compounds; - The chelating agents EDTA, DTPA, NTA or phosphonates; - The following fragrances: Moskusxylene ( ), Moskusambrette ( ), Moskene ( ), Moskustibetin ( ), and Moskusketone ( ); - Xylene sulfonates or other linear alkyl benzene sulfonates. The product must not contain any substances which are deemed to be potentially bioaccumulative. A substance is classified as potentially bioaccumulative if the log K OW (log octanol/water partition coefficient) is equal to or greater than 3. New criteria added to reflect the strengthen requirements of the revised standard.

8 LIMITED SUBSTANCES Products shall not contain carcinogenic substances in categories 1, 2A as classed by the IARC at levels which expose the user at a maximum of 1/20th of the allowable limit determined by the NOHSC and/or NICNAS. Components ranked within the top 200 toxic compounds listed in the Australian National Pollutant Inventory (NPI) shall not exceed 1% by volume. The total amount of components classified as hazardous to the environment shall not exceed 2% by volume. OZONE DEPLETING SUBSTANCES Solvents used to clean production equipment must have an ozone depletion potential of zero. Pressurised spray cans must not contain ozone depleting substances as listed in Annex A, B or C of the Montreal Protocol. PRODUCT INFORMATION The manufacturer must provide written information to the consumer clearly stating: - Instructions for proper use; - A list of ingredients which complies with the EEC Commission Recommendation for Labelling of Detergents and Cleaning Products; - Environmentally responsible disposal instructions; and - If product is for export, instructions for use must be provided in appropriate languages. The product must not contain more than 1% by weight of any substance that carries one or more of the following risk phrases: IARC Group 2B* * Titanium dioxide is excluded from this restriction when used as a pigment in cosmetics only (excluding sunscreens). Additionally, products which are intended to be immediately rinsed off with water must not contain more than 1% by weight of any substance that carries one or more of the following risk phrases: R50 (H400), R50/53 (H410), R51/53 (H411), R52/53 (H412), R53 (H413). Exemption: Surfactants in concentration <25% are exempt if the 1% limit was based only on a R50 (H400) classification. Following information must be included on the label: - Instructions for correct use including doses or dilution rates for varying levels of soiling; - All hazards associated with the product, its use, storage or disposal; - Complete ingredients listing, according to Annex VII of the European Union Commission Directive 89/542/EEC ; - An instruction for users to read the SDS. - Following information must be available to the public: - Safety data sheet (SDS); - Technical data or product information sheets; and Environmentally responsible use and disposal instructions including product stewardship; Criteria updated to reflect the strengthened requirements of the revised standard. Criterion removed as made redundant by banning halogenated compounds and aerosol products. Criterion expanded to include further information for the consumer. New label requirements include disclosure of hazards associate with the product and an instruction for the user to read the SDS. Safety data sheets and technical data must also be made publicly available.

9 PACKAGING Used packaging shall be able to be recycled by local recycling systems. Packaging must comply with at least one of the following: - Each material constituting >20% by weight of the total primary and secondary packaging used, must contain at least 50% recycled content by weight; - Each material constituting >20% by weight of the total primary and secondary packaging used, must be derived from plant-based materials (e.g. PLA plastics); - Each material constituting >20% by weight of the total primary and secondary packaging used, must be compostable to a relevant ASTM or ISO standard; - Each material constituting >20% by weight of the total primary and secondary packaging used, must be biodegradable to a relevant ASTM or ISO standard such as ASTM D5511; or - Packaging (primary and secondary) must be assessed using the Australian Packaging Covenant s Packaging Recyclability Evaluation Portal (PREP). Each separable item constituting >20% by weight of the total primary and secondary packaging, must be classified as Recyclable under the Item Assessment Result of the PREP Assessment Report. Paper and cardboard packaging must be either certified under recognised forest certification scheme (e.g. FSC or PEFC) or contain at least 30% recycled content by weight. Material used for the transport of products (tertiary packaging) and whose disposal is not the responsibility of the end consumer may be exempt from the above requirements if they are re-used by the applicant, or are recyclable in specialist recycling facilities. Refill packaging aimed to minimise material usage is exempt from this criterion. Criterion expanded to strengthen requirements and address innovative packaging types. PREP included in criterion to support the initiative and tool and to help determine recyclability in the Australian kerbside system.

10 Chlorinated or halogenated plastics must not be used in product packaging. The appropriate resin code for the type of plastic used in packaging must be stamped on each unit sold to facilitate recycling. WASTE MINIMISATION SOCIAL AND LEGAL COMPLIANCE Compliance to environmental regulations Compliance to labour, anti-discrimination and safety regulations Packaging must not be halogenated. All plastic bottles and other major or primary packaging must be marked with a plastics identification code. It is not mandatory for small components including caps and pump-spray nozzles to be marked. Packaging made from PLA plastic must be labelled with the following instructions for disposal: This packaging is made of PLA plastic. Please dispose of in a municipal organic waste stream. Packaging must not be pressurised or require the use of propellants. The applicant must demonstrate that at least 97% of material inputs (ingredients) result in product and that effective waste management / material efficiency policies and procedures are developed and implemented, including: - Waste minimisation policies and procedures to reduce the amount of waste generated; - Waste recovery procedures to capture and reuse as much waste as is practical; - Efficient use of resources through dematerialisation; and - Energy conservation policies to reduce energy consumption. Environmental Legislation Fair Pay Workplace Safety Equal Opportunity Lawful Conduct Criterion expanded to strengthen requirements and address innovative packaging types. New criterion added as part of a wider movement to ensure all GECA standards address waste minimisation. Most recent Social and Legal Compliance criteria included.